§ 12:61 Suggested motion text

“[Name of moving party] hereby moves this Court for an order determining [insert issue
that is question of law, e.g., interpretation of policy terms; issue of equitable estoppel;
insurer's duty to defend; etc.] and excluding any and all evidence, testimony or argument
pertaining to [insert issue that is question of law, e.g., interpretation of policy terms; issue of
equitable estoppel; insurer's duty to defend; etc.]. The motion is based upon the grounds that
such evidence is improper and inadmissible and would therefore create a substantial
danger of unfair prejudice to the moving party.”